Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Principles of Natural Justice - The petitioner instead of appearing through a legal representative before the adjudicating authority was kept on corresponding for supply for entire data collected by the respondents during the search. No such demand was made by the person from whose possession the data was seized - Even otherwise appellate authority is competent to examine the effect non-supply of non relied upon documents/ data while deciding the appeal. Even otherwise there are details of the data demanded by the writ petitioner only for the sake of delaying the proceedings simply letters were sent. - Petition dismissed - HC
Principles of Natural Justice - The petitioner instead of appearing through a legal representative before the adjudicating authority was kept on corresponding for supply for entire data collected by the respondents during the search. No such demand was made by the person from whose possession the data was seized - Even otherwise appellate authority is competent to examine the effect non-supply of non relied upon documents/ data while deciding the appeal. Even otherwise there are details of the data demanded by the writ petitioner only for the sake of delaying the proceedings simply letters were sent. - Petition dismissed - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
